News & Analysis as of

Banks Office of the Comptroller of the Currency Regulatory Agencies

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...more

Orrick, Herrington & Sutcliffe LLP

OCC removes reference to disparate impact for examiners

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also...more

Ballard Spahr LLP

Jonathan Gould confirmed as Comptroller of the Currency

Ballard Spahr LLP on

The Senate has confirmed Jonathan Gould as Comptroller of the Currency. Gould, who served as Senior Deputy Comptroller and Chief Counsel at the OCC during President Trump’s first term, was confirmed 50-45. Every Democrat...more

Orrick, Herrington & Sutcliffe LLP

Agencies allow banks to access tax ID numbers from third parties

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Ballard Spahr LLP

Fed to end use of reputational risk in examination programs

Ballard Spahr LLP on

The Federal Reserve Board has announced that it will eliminate reputational risk as a component of examination programs in its supervision of banks. ...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its May 2025 CRA performance evaluations

On June 2, the OCC released a list of CRA performance evaluations that became public during the month of May. The OCC evaluated 18 banking entities, including national banks, federal savings associations, and insured federal...more

Orrick, Herrington & Sutcliffe LLP

Regulators withdraw crypto guidance, plan further clarity for banks

On April 24, the FDIC and the Fed announced they have retracted two joint statements concerning banking organizations’ activities related to crypto-assets. According to the agencies, this move aims to clarify that banking...more

Jones Day

Federal Reserve Withdraws Crypto-Related Guidance Including Notification Requirements for Banking Organizations

Jones Day on

The Federal Reserve Board ("Board") softened its stance on regulation of crypto activity by banking organizations by rescinding supervisory letters that created hurdles for crypto-asset activities and by joining the Office of...more

Orrick, Herrington & Sutcliffe LLP

OCC releases April 2025 enforcement actions

On April 17, the OCC announced enforcement actions against three institution-affiliated parties, alleging in the first instance fund misappropriation, in the second Paycheck Protection Program fraud, and in the last...more

Mayer Brown

OCC Withdraws Climate Risk Management Principles

Mayer Brown on

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Signal Reversal on 2023 CRA Modernization Rule

On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

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